In this privacy policy (Privacy Policy), “we“, “us” and “our” means Thread Capital Partners Pty Ltd (ABN 26 644 823 969) and includes a reference to our related entities.

What is the Privacy Policy about?

We are committed to respecting your privacy and to dealing with your personal information in accordance with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles. This Privacy Policy sets out how and why we collect, use, hold and disclose your personal information (Information). By providing Information to us, you consent to us collecting, holding, using and disclosing your Information in accordance with this Privacy Policy, any other arrangements that apply between us and as otherwise permitted by law.

What is personal information?

Personal information is any information or opinion about an individual (you), or from which you can be reasonably identified. Information or an opinion may be personal information regardless of whether it is true or not. We may ask you for personal information when we assist you or a company, or group of companies, which you own or control or for which you materially influence decision making (your related entities) to arrange debt and/or equity capital (capital). We use the information you provide to advise about and assist with your capital requirements and the capital requirements of your related entities. We only provide your information to the financiers with whom you advise us you want to deal with.

What Information do we collect and hold?

We may collect Information about you and your interactions with us, for example, when you use any of our services, contact us or otherwise visit our website.

The Information we may collect may include:

(a) your name, address, date of birth and contact details;

(b) your education and employment history;

(c) information contained in identification documents, such as a passport or driver’s licence;

(d) financial information such as your credit or debit card and bank account details;

(e) details of your financial circumstances, including your assets and liabilities, income, expenditure and insurance cover;

(f) your use of our services;

(g) details of enquiries or complaints you make;

(h) any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information;

(i) information about how you access, use and interact with the website, including the location from which you have come to the site and the pages you have visited and other technical data, including IP address, device attributes and browser type; and

(j) any other information that we may require to facilitate your dealings with us. Generally, we will not collect sensitive information about you unless required to do so by law or unless you provide consent. Sensitive information includes information about your race or ethnicity, political opinions or associations, religious or philosophical beliefs, criminal record, sexual orientation or health, genetic or biometric information.

Why do we collect, hold and use your Information?

We collect, hold and use your Information so that we can:

(a) provide you or your related entities with our services;

(b) assist you to demonstrate to providers your suitability to act as guarantor or to provide other support for the provision of capital to your related entities;

(c) arrange capital for your related entities;

(d) assist you to satisfy any know-your-client, anti-money laundering and counter-terrorism financing processes and procedures of financiers or prospective financiers that you or your related entities wish to engage with;

(e) contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;

(f) keep you informed of the services we offer and industry developments that may be of interest to you, and to notify you of service offerings, seminars and other events;

(g) perform internal functions such as general administration, management and reporting, including invoicing and processing payment transactions;

(h) comply with our legal obligations and assist government and law enforcement agencies or regulators;

(i) provide you with direct marketing about other products or services that we think may be of interest to you;

(j) contact you to ask for a testimonial or to complete a client satisfaction survey; and

(k) carry out other purposes related to our business and as otherwise permitted by law.

How do we collect your Information?

Generally, we collect Information directly from you. We may do this whenever you interact with us, including through forms filled out by you, face to face meetings, email messages, telephone conversations or when you use our website. We may also obtain personal information about you from third parties including your representatives (such as your legal or financial adviser), your related entities publicly available sources of information and anyone else who you refer to us or who refers you to us. 

How do we store and hold Information? 

We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you may be recorded in paper files. We implement and maintain processes and security measures to protect Information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. These processes and systems include: 

(a) all electronically stored personal information being protected by an encrypted secure network; 

(b) limited paper files being retained, with paper files containing personal information being scanned or otherwise uploaded to retain an electronic copy while the original paper file is shredded and securely disposed; 

(c) requiring all employees to comply with internal information security policies and keep information secure; and 

(d) monitoring and regularly reviewing our practise against our own policies and against industry best practice. 

We will also take reasonable steps to destroy or de-identify Information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the Australian Privacy Principles. 

Who do we disclose your Information to, and why?

Generally, we only use or disclose your Information for the purposes for which it was collected (as set out above). In conducting our business and/or provide our services, we may disclose your Information to: 

(a) our employees and our related entities; 

(b) your authorised representatives (such as legal and financial advisers); 

(c) your related entities; 

(d) financiers and prospective financiers that you or your related parties have agreed to deal with; 

(e) third party service providers who assist us in operating our business (including credit reporting bodies and technology service providers); 

(f) government or regulatory bodies (such as the Australian Securities and Investments Commission and Australian Transaction Reports and Analysis Centre); 

(g) other parties that may reasonably be expected to participate in the process of us obtaining access to capital on behalf of you and your related entities (including for the purposes of carrying out due diligence and valuations); and 

(h) any organisation providing verification (including online verification) of your identity. 

We may also disclose your Information to third parties where: 

(a) we are required or authorised by law to do so; 

(b) you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or 

(c) we are otherwise permitted to disclose the information under the Act. 

If we consider the disposal or sale of our business or assets, we may disclose your Information to bona fide purchasers in order for them to conduct necessary due diligence investigations. If the ownership or control of all or part of our business changes, we may transfer your Information to the new owner. 

What is credit information? 

Credit information is personal information about your credit worthiness, credit standing, credit facilities and repayment history. It also includes information about your credit capacity that is supplied to us by a credit reporting body and any information that we derive from it. 

Credit information and our Credit Reporting Policy The Act contains provisions regarding the use and disclosure of credit information, which applies in relation to the provision of both consumer credit and commercial credit. Where we provide terms of payment of accounts which are greater than 7 days, we are considered a credit provider under the Act in relation to any credit we may provide you (in relation to the payment of your account with us). 

We use credit-related personal information for the purposes set out in our Credit Reporting Policy. We will store credit-related personal information you provide us, or which we obtain about you, in accordance with our Credit Reporting Policy. Please refer to our Credit Reporting Policy if you wish to make a complaint about our handling of your credit-related personal information. 

Do we disclose Information to overseas recipients? 

In some circumstances, the parties with whom we disclose your Information may be located outside Australia or engage other parties overseas. Additionally, our data storage providers may be located outside Australia. It is not always practicable to find out where your Information may be accessed or held, as electronic or networked storage can be accessed from various countries via an internet connection. We will take reasonable steps to ensure that any overseas recipient will deal with such Information in a way that is consistent with the Act. 

Do we use your Information for marketing? 

We may use your personal information to send you direct marketing communications and information about products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related entities, business partners or service providers. Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication. 

Links 

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Privacy Policy, so we encourage individuals to read them before using those websites. 

Access to and correction of your Information 

You may access or request correction of the Information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your Information. 

We will provide you with a written notice that sets out the reasons for the refusal unless it would be unreasonable to provide those reasons. We do not charge you for requesting access to your Information, but we may require you (where permitted by law) to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We may need to consult with credit providers or other credit reporting bodies to resolve the correction request. 

We will respond to your requests to access or correct Information in a reasonable period of time and will take all reasonable steps to ensure that the Information we hold about you remains accurate, up to date, complete, relevant and not misleading.

Privacy breaches 

We will deal with privacy breaches in an appropriate and timely manner. There may be internal and external actions that need to be taken. In taking any action, we will be guided by the steps suggested by the Office of the Australian Information Commissioner on responding to a breach (whether it is actual or suspected). 

Complaints 

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your Information or believe we are in breach of Part IIIA of the Act or the Privacy (‘Credit Reporting’) Code 2014 (Version 2.1), you should contact us. Our contact details are set out below. 

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation. 

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available. 

Contact details 

If you have any questions, comments, requests or concerns, please contact us at: 

David Clarke
Managing Director and Privacy Officer
E: david.clarke@threadcapital.com.au
A: Suite 2.1, Level 2, 328 Scottsdale Drive, Robina, QLD, 4226 

Changes to this Privacy Policy 

From time to time, we may change our Privacy Policy on how we handle Information or the types of Information which we hold. Any changes to our Privacy Policy will be published on our website. You may obtain a copy of our current Privacy Policy from our website or by contacting us using the details above. 

Effective: March 2021